Banks and credit unions must complete a risk assessment and then develop an action plan and timeline to fulfill the requirements of the new guidelines. Anomaly detection is one area that may take more time for institutions to implement then the 180 days given by the FFIEC. BITS, a division of The Financial Services Roundtable, is working with members in areas such as anomaly detection and helping them develop best practices. “The work could be completed within months, but the release date is somewhat of an unknown factor or wild card,” says William Henley.”]
Source: https://www.cuinfosecurity.com/meeting-ffiec-guidance-deadline-a-3918

